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There’s nothing “wrong” with protests built around placard-hoisting and park-squatting, but Occupy the SEC is definitely doing something right with its radically different tack. The OWS-offshoot has submitted a 325-page letter to federal financial regulatory agencies on the Volcker Rule, a controversial measure designed to prohibit banks from proprietary trading, or making investments with their own dollars rather than their customers’, that was passed as part of the Dodd-Frank financial reform law.

When Congress writes a bill, even a really, really long bill, its directions are often vague and incomplete. In order for a law to be practically applied, relevant federal agencies must translate vague legislativese into enforceable rules. This takes time, and a surprisingly large amount of a given regulation’s scope and effectiveness can be determined in this critical period. But while most of the media (TIME included) and, by extension most lay-folks, follow congressional debate over a major piece of legislation like Dodd-Frank, they tend to ignore the rule-writing period. By contrast lobbying interests who have a major stake in the outcome of said rules do not, and they can often win tweaks in their favor after the public has turned its back. (Not there’s anything inherently wrong with that: these are businesses that will be directly affected by such rules and can be expected to advocate for themselves.) Case in point: The Financial Services Forum, a consortium of top banking CEOs, actually spent more on lobbying in 2011, when Dodd-Frank’s most important regulations were under review, than in 2010, when the law was debated and passed. The industry as a whole spent about the same in each year.

All of which is to say that showing up in this latter stage of lawmaking is a really important part of public policy advocacy, and it’s not something that grassroots groups often have a good handle on. Occupy the SEC is doing its occupying in smart way. For a substantive overview of Occupy the SEC’s concerns about Volcker–in short, they’re worried that banks have secured loopholes to get around the spirit of the rule–read Felix Salmon or the entire letter.